ML20053C891

Application for Amend to Licenses DPR-77 & DPR-79,changing License Conditions Re Environ Qualification of safety- Related Electrical Equipment (Ref NUREG-0588) & Control Room Design Review

ML20053C891
Person / Time
Site:	Sequoyah
Issue date:	05/25/1982
From:	Kammer D TENNESSEE VALLEY AUTHORITY
To:	Adensam E Office of Nuclear Reactor Regulation
References
RTR-NUREG-0588, RTR-NUREG-588 NUDOCS 8206030121
Download: ML20053C891 (10)

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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374ot 400 Chestnut Street Tower II May 25, 1982 Director of Nuclear Reactor Regulation ,

Attention: Ms. E. Adensam, Chief Licensing Branch No. 4 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Ms. Adensam:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 In accordance with 10 CFR Part 50.90, enclosed are 40 copies of proposed revisions to the Sequoyah Nuclear Plant Operating Licenses DPR-77 (Enclosure 1) and DPR-79 (Enclosure 2). The proposed license amendments request changes in the operating license conditions regarding environmental qualification of safety-related electrical equipment (NUREG-0588) and controi room design review for each unit. Each enclosure identifies the existing conditions, the proposed changes, and the basis for each change.

Enclosure 1 provides the requested changes in the unit 1 operating license, DPR-77; and Enclosure 2 provides the requested changes in the unit 2 operating license, DPR-79.

In accordance with the provisions of 10 CFR Part 170, we have determined the changes to be Class II for unit 1 and Class I for unit 2. These classifications are based on the facts that the amendment is adminis-trative in nature and that the changes apply to two identical units on the same site. The remittance fee of $1,600 is being wired to the Nuclear Regulatory Commission, Attention: Licensing Fee Management Branch.

Very truly yours, TENNESSEE VALLEY AUTHORITY os M D. S. Kammer Sworn to and subscribed before me Nuclear Engineer Dh[

this M day of (2 vV' 1982 f

[ G!4 Lush a K! . I (

Notary /Public //

My Commission Expires

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f f'd Enclosure (40) cc: See page 2 8206030121 820525 PDR ADOCK 05000327 PDR An Equal Opportunity Employer p

Director of Nuclear Reactor Regulation May 25, 1982 cc: U.S. Nuclear Regulatory Commission Region II Attn: Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

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ENCLOSURE 1

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PROPOSED CHANGES '11) 711E SEQUOYAH NUCLEAR PLANT UNIT 1 )

OPERATING LICENSE

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ltem (1) - Environmental Qualification of Safety-Related Electrical Eautoment E11stine Conditions 2.C(12).a No later than November 1,1980, TVA shall submit information to show compliance with the requirements of NUREG-0588, 'Interin Staff Fosition on Environmental Qualification of Safety-Related Electrical Equipment,' for safety related equipment exposed to a harsh snvironment. Implementation shall be in accordance with NUREG-0588 by June 30, .1982.

2.C(12).b By no later than December 1,1980, complete and auditable records must be available and maintained at a central location which describe the environmental qualification method used for all safety related electrical equipment in suf ficient detail to document the degree of compliance with the DOR Guidelines or NUREG-0583. Thereafter, such records should be updated and maintained current a s equipment is replaced, further tested, or otherwise further qualified to document complete compliance by June 30,1982.

2.C(12).c By no later than June 30, 1982, all safety-related electrical equipment in the facility shall be qualified in accordance with the provisions of: Division of Operating Reactors ' Guidelines for Evaluating Environmental Qualification of Class IE Electrical Equipment in Operating Reactors' (DOR Guidelines); or NUREG-05 88, ' Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment,' December 1979. Copies of these documents are attached to the Order for Modificaton of License DPR-77 dated November 6,1980.

Pronosed Channes 2.C(12).a No later than November 1,1980, TVA shall submit information to show compliance with the requirements of NUREG-0588, ' Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment ,' for safety-related equipment exposed to a harsh environment. Implementation shall be in accordance with NUREG-0588 by the end of the second refueling outage after March 31,1982 but not later than November 30, 1985.

2.C(12).b By no later than December 1,1980, complete and auditable records must be available and maintained at a central location which describe the environmental qualification method used for all safety-related electrical equipment in sufficient detail to document the degree of compliance with the DOR Guidelines or NUREG-05 88. Thereafter, such records should be updated and

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• i 1 maintained current as equipment is replaced, further tested, or otherwise further qualified to document complete compliance by 1 the end of the second refueling outage after March 31,1982 but )

no later than November 30, 1985. l l 2.C(12).c All safety-related electrical equipment in the facility shall be qualified in accordance with the provisions of: Division of '

Operating Reactors ' Guidelines for Evaluating Environmental Qualification of Class IE Electrical Equipment in Operating l Reactors * (DOR Guidelines): or NUREG-0588, ' Interim Staff Position on Environmental Qualification of Safety-Related i

Electrical Equipment,' December 1979, or the requirements of proposed regulation, 10 CFR 50.49, ' Environmental Qualification of Electrical Equipment for Nuclear Power Plants,' by the end of the second refueling outage after March 31, 1982 but no later than November 30, 1985.

Justification In previous submittals to the NRC to comply with the requirements of NUREG-0588 and with the requirements of 2.C(10).c of the unit 2 operating license for the Sequoyah Nuclear Plant, we have indicated that we would make overy reasonable effort to comply with the requirements of NUREG-0588.

In the July 7-10, 1981 neeting with NRC on equipment qualification, we indicated concerns with our ability to comply with the deadline and provided examples and reasons. A sammary of examples is provided in Attachment 1. These examples are typical of the inability to obtain qualified components by the current deadline.

We, therefore, recommend that the deadline be in accordance with the replacement schedule established by each utility that is reviewed and l approved by the NRC but consistent with the implementation schedule provided in the proposed addition (50.49) to the Code of Federal Regulations. The schedule proposed by the new regulation 50.49 has final environmental qualification by the second refueling outage af ter March 31, 1982 but no later than November 30, 1985. We believe that continued operation of our Sea,noyah Nuclear Plant is justified.

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Item (2) - Control Room Deslan Enistin. Condition Prior to start-up af ter first refueling, TVA shall complete the detailed Control Room Design Review. As part of this review, TVA shall consider benefits of installing data recording and logging equipment in the control '

room to correct the deficiencies associated with the trending of important parameters on strip chart recorders used in the control room.

Pronomad Conditio.A TVA shall complete the detailed control room design review in accordance with the schedule to be spscified for operating reactors in NUREG-0700. As part of this review, TVA shall consider benefits of installing data recording and logging equipment in the control room to correct the deficiencies associated with the trending of important parameters on strip chart recorders used in the control room.

Justifloation As stated in the Sequoyah SER, Supplements 2 and 5, we have taken correct i actions to improve the operator effectiveness during an upset or accident condition. The NRC concluded that Sequoyah could be safely operated with these improvements. However, we were required to complete the detailed control room review on the same schedule as other licensees with operating plants. Even though NUREG-0700 was officially issued during the f all of 1981, no implementation schedule has yet been defined.

i At the time the existing license condition was issued on unit 1 of our Sequoyah Nuclear Plant, this date was thought to be consistent with the expsoted implementation schedule for the detailed control room review, that would be included in NUREG-0700. Since this schedule has changed significantly, and in order to be consistent with our understanding of the intent to the requirement as stated in the Sequoyah SERs, we propose changing the license condition to coincide with the schedule to be imposed

on other licensees of operating reactors. We believe that continued operation of the plant is justified.

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ATTAGMENT 1 TO ENCLOSURE 1 Examples of Equipment Not Capable of Meeting the June 30, 1982 Deadline

1. Pressure transmitters (PT) and differential pressure transmitters (DPT), 10-50MA range: Barton appears to be on the only source for qualified instruments capable of meeting TVA's requirements.

Qualification is expected in October 1981 and procurement lead time would result in delivery in later 1982. This date could be severely delsyed if other utilities tax Barton's production capabilities.

2. Pressure switches, dif ferential pressure switches and flow switches:

The ASCO models may have to be totally rotested to meet qualification req 3irements. Completion of qualification testing is not expected until February 1983. Comparable Barton instruments lack adequate

, seismic qualification and would require modification or further testing. Additionally, suppliers will not test to TVA's specific (extreme) environmental conditions. Procurement delivery dates cannot be expected until 1984.

3. Level switches, fl ow type: Magnetrol appears to be the only source for qualified instruients: howev e r, the qualification testing is not expected until 1983 and delivery in 1984.

4. 4160/480-V transformers: Procurement of qualified replacement components will require significant lead time sud delivery is expected in late 1983.

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ENCLOSURE 2 ;i PROPOSED CHANGES TO 'IEE SBQUOYAH NUCLEAR PLANT UNIT 2 OPERATING LICENSE Item (1) - Environmental Qualification of Safetv-Related Eauinment.

NUREG-0588 Existina Conditions 2.C(10).a No later than June 30, 1982,' 'IVA shall be in compliance with the requirements of NUREG-0588, ' Interim Staff Position on Environmental Qualification of safety-Related Electrical Equipment,' for safety related equipment exposed to a harsh environment .

2.C(10).b Complete and auditable records must be available and maintained -

at a central location which describe the environmental qualification method used for all safety-related electrical equipment in sufficient detail to document the degree of compliance with the DOR Guideline s or NUREG-0588. Such records should be updated and maintained current as equipment is i replaced, further tested, or otherwise further qualified to document complete compliance by June 30, 1982.

2.C(10).c Within 90 days of receipt of the equipment qualification safety evaluation, the licensee shall either (1) provide missing documentation -identified in Sections 3 and 4 of the equipment qualification safety evaluation which will demonstrate compliance of the applicable equipment with NUREG-0588, or (ii) commit to corrective actions which will result in documentation of compliance of applicable equipment with NUREG-0588 no later than June 30, 1982.

Pronomad Conditions 4 ,

2.C(10).a 'IVA shall be in compliance with the requirements of NUREG-0588,

' Interim Staff Position on Environmental Qualification of Saf ety-Related Electrical Equipment, ' for safety-related equipment exposed to a harsh environment, or the requirements of the proposed regulation, 10 CFR 50.49, ' Environm ent al Qualification of Electrical Equipment for Nuclear Power Plants,'

by the end of the second refueling outage af ter March 31, 1982 but no later than November 30, 1985.

2.C(10).b Complete and auditable records must be available and maintained at a central location which describe the environmental qualification method used for all safety-related electrical ,

equipment in sufficient detail to document the degree of compliance with the DOR Guideline s or NUREG-0588 Such records

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should be updated and maintained current a s equipment is replaced, further tested, or otherwise further qualified to l docum ent complete compliance by the date required by the proposed regulation 50.49, ' Environmental Qualification of Electrical Equipsent for Nuclear Power Plants.'

2.C(10) c Mithin 90 days of receipt of the equipment qualification safety evaluation, the licensee shall either (i) provide missing documentation identified in Sections 3 ar.d 4 of the equipment qualification safety evaluation which will demonstrate compliance of the applicable equipment with NUREG-0588, or (ii) commit to corrective actions which will result in documentation of compliance of applicable equipment with NUREG-0588 by the date required the proposed regulation 50.49, ' Environmental Qualification of Electrical Equipment for Nuclear Power Plants.'

Justification Same as for unit 1.

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,Page 3 Item (2) - Control Room Dealan Review Enlatina Condition Prior to startup af ter first refueling of unit 1 or unit 2, whichever osents first, TVA shall complete the detailed Control Room Design Review.

As part of this review, TVA shall consider benefits of installing data recording and logging equipment in the control room to correct the deficiencies associated with the trending of important parameters on strip ,

chart recorders used in the control room.

Pronosed Condition TVA shall complete the detailed control room design review in accordance with the schedule to be specified for operating reactors in NUREG-0700. As part of this review, TVA shall consider benefits of installing data recording and logging equipment in the control room to correct the deficiencies assoaisted with the trending of Important parameters on strip chart recorders used in the control room.

J us t if lo at ion Same as for unit 1.

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